Beck

Defendant State Farm Mutual Automobile Insurance Company appeals the judgment and order denying its motion for judgment notwithstanding the verdict after the jury assessed $25,000 compensatory damages and $75,000 punitive damages in favor of plaintiff Nanci Beck on a cause of action for breach of an insurer’s obligation to act in good faith and deal fairly with its insured.

Beck charged State Farm with unreasonable refusal to negotiate or settle an “uninsured motorist” claim under her automobile liability insurance policy. State Farm contends the evidence shows it acted in good faith and without malice, that it believed it had a valid defense to Beck’s uninsured motorist claim based on her alleged failure to report her hit-and-run accident to the police or Department of Motor Vehicles within 24 hours.

The Policy

Pursuant to Insurance Code section 11580.2, Beck’s automobile liability insurance policy provides that State Farm will “pay all sums [up to $15,000] which [Beck] shall be legally entitled to recover as damages from the owner or operator of an uninsured automobile because of bodily injury sustained by [Beck], caused by accident and arising out of the ownership,…